Unchained - Is the Government Trying to Kill Off Crypto in the US? - Ep. 476

Episode Date: April 4, 2023

Brian Quintenz, head of policy for a16z crypto, and Nic Carter, general partner at Castle Island Ventures, talk about Operation Choke Point 2.0, the relationship between the government and the crypto industry, the status of different tokens as securities or commodities, and potential future developments in the space Show highlights: what the original Operation Choke Point was like the "evidence" that shows that Operation Choke Point 2.0 against crypto is real, according to Nic  how hard it is for crypto companies to get banked in the U.S. whether crypto had anything to do with the current banking crisis whether agencies such as the CFTC and the SEC are performing coordinated action against the industry how the collapse of FTX changed the approach of banking regulators toward crypto whether the U.S. needs to change its regulatory approach to maintain its status as a global leader whether crypto is a threat to the U.S. dollar and the financial system how Tether has benefited from the recent regulatory events why Brian says that the SEC has already demonstrated that BTC and – also ETH -- are not securities Thank you to our sponsors! Crypto.com Halborn Guests: Brian Quintenz, head of policy for a16z crypto Nic Carter, general partner at Castle Island Ventures Did The Government Start A Global Financial Crisis In An Attempt To Destroy Crypto? Operation Choke Point 2.0 Is Underway, And Crypto Is In Its Crosshairs Previous coverage of Unchained on the banking situation: Jim Bianco on Why the Banking System Has Always Been Broken The Fed Is In Checkmate: What Will Powell Do? The Fall of SVB: What Happened and How It Affects Crypto Previous coverage of Unchained on the recent regulatory crackdown:  Why the CFTC Case Against Binance Will Have Very Important Consequences for Crypto Coinbase’s Top Lawyer Calls SEC Wells Notice a ‘Massive Overreach’  Links NYMAG: Barney Frank Talks More About the Surprise Shuttering of Signature Bank Unchained: Was Signature Bank Actually Insolvent? Regulators Close Signature Bank Following SVB Collapse CFTC Sues Binance and CZ Over US Regulatory Violations CoinDesk Editorial: It Sure Looks Like the U.S. Is Trying to Kill Crypto The Administration’s Roadmap to Mitigate Cryptocurrencies’ Risks | NEC | The White House Learn more about your ad choices. Visit megaphone.fm/adchoices

Hi everyone. Welcome to Unchained, your no-hype resource for all things crypto. I'm your host, Laura Shin, author of The Cryptopians. I started covering crypto seven years ago, and as the senior editor of Forbes, was the first Main Tree Media Reporter to cover cryptocurrency full-time. This is the April 4th, 2020 episode of Unchained. Web3 projects lost nearly $4 billion of crypto assets in 2022, but nothing is more expensive than losing trust. Secure your company with Hallborn's best-in-class security advisory solutions. Visit halborn.com for more. Buy, earn, and spend crypto on the crypto.com app.

New users can enjoy zero credit card fees on crypto purchases in the first seven days. Download the crypto.com app and get $25 with the code Laura. Link in the description. Today's topic is the U.S. crackdown on crypto. Here to discuss are Brian Quintens, head of policy for A16C crypto, and Nick Carter, General Partner at Castle Island Unchers. Welcome, Brian and Nick. Thanks, Laura. Thank you. In recent months, the U.S. government has been cracking down on the crypto industry in a number of ways. Let's start with what appears to be the first inkling of a more

coordinated effort, which, Nick, I believe you dubbed Operation Chokepoint 2.0. And you first identified this in a Pirate Wire's article. And I was wondering if he could explain what Operation Chokepoint 2.0 is and what evidence you have that this is actually happening. Sure. So the name obviously is a callback to Choke Point. It was just called Operation Choke Point, which was actually the official government name, which took place from about 2012 to 2017 with varying degrees of intensity. And it was an attempt to basically marginalize certain industries in the U.S. by persuading the banks not to do business with them. And the primary agencies that were responsible for this

was the FDIC in conjunction with the DOJ, and the OCC was involved to a lesser extent. And the primary targets were just politically unfavored industries. So payday lending, I would say, is the number one target of choke point 1.0 and some other industries were also targeted like firearms manufacturing. And basically the objective was to marginalize those industries, not through Congress or any sort of formal process, but by having the bank regulators tell the banks that there was reputational risk in serving those industries. And that was the problem was that it wasn't

really done through legal means. It was done by insinuation and by casting aspersions against the industry and suggesting to the banks that they would face reputational risks and more owner's oversight if they banked them. And it was pretty successful. Now, 2.0 is similar. I would say it's more explicit, actually. It's less subtle. It's less under the table. It's more overt. It's in plain sight, for the most part. And the target is the crypto space. So, of course, there's a lot to discuss for a regulatory perspective with regards to crypto. So, of course, there's the SEC and the CFTC and there's all of those undertakings. But the primary thing that I'm calling chokepoint 2.0 is happening through bank regulation.

And it is coordinated, for sure. It concerns the Fed, the OCC, and the FDIC, and also the administration itself. And the evidence that I started to see really became clear in January. Our portfolio companies reported to us they were having trouble with their banking. Certain bank executives I talked to indicated to me that they were facing more onerous data requests from their regulators. Of course, we saw what happened to Silvergate and Signature. Those aren't evidence on their face, but certainly the circumstances of signatures receivership were suspicious, given that it's probably the first fully solvent bank that was put into receivership in the U.S. and this is a large bank. So it's lots of suspicions around that, including what Barney Frank had to say.

But I would say the evidence is simply the fact that starting in January, really, all these agencies started saying at the same time that banks serving the crypto space was a threat to the safety and soundness of these banks. We now know over and above that that the Fed and the FDIC have been pressuring banks not to do business with the crypto space. and I'm sure more evidence will come out in time. But I'd say the totality of the evidence, you can also point to the disapproval of custodious license and the troubled state of the federally chartered crypto institutions like Pretigo. I think the totality of the evidence suggests very clearly now

that there is a coordinated cross-agency attempt to really limit the ability of the crypto industry to obtain banking in the U.S. And so that's why I call it chokepoint 2.0. And earlier when you said that your portfolio companies were saying they had trouble with their banks, how do you define that? Well, obviously when startups raise capital, one of the first things you do is just got a bank relationship.

And that should be trivial, right? Any legal business in the U.S. should not have trouble obtaining banking. But the reality today is there's only a handful of banks that service crypto firms, the ones that do face higher costs for doing that if they're perceived to be crypto-friendly banks. And so it's not worth it for them to take on smaller clients for the most part. Additionally, banks face these de facto limits on how many deposits they can take on. There's these informal thresholds that are now message to banks in the kind of 10, 15% range. So today, post-Silvergate and signature collapses, no bank can be an explicitly wholly

crypto bank. The banks that are doing business with the crypto space have these effective limits of deposits that they can take. So basically, if you're a crypto company, you go to any of these banks that are known to service crypto, you'll still have trouble persuading them to take you on as a client. A lot of banks just have a straight-up ban on crypto. They'll just say, we literally don't service businesses that do crypto stuff. And the banks that do are pretty averse to giving you actual merchant accounts. So if you think of an exchange where you're processing transactions on behalf of your clients, wires in and out, that is sort of the more full service type banking engagement. That is extremely hard to get today. So if you're a crypto firm, you go to a bank,

you ask for an account, they may give you an operating account, basically just for cash management, but going for the fuller merchant account, that's extraordinarily difficult today. And that's the unfortunate reality. And Brian, what have you been hearing from the A16Z portfolio companies in terms of their banking relationships? Yeah, thanks, Laura. So I can't speak to any one specific company, but generally we have seen portcoes being debanked. That said, so far all of our portcoes have found banking partners, but it highlights, I think, the importance of smaller and regional banks in the U.S. startup ecosystem. There needs to be banks and institutions that service that industry, and that know that business model. Generally thinking about this, you know, from a first principles

standpoint, you know, banks are in the business of accepting risk and managing risk. And banks manage risk from like the unique characteristics of the customer in the industry. And crypto is no different. Crypto businesses can pose risk to banks, but they have tools to manage those risks, just like they have tools to manage risks of other types of industries and other specific types of companies, especially when it comes to diversification across very large balance sheets. Again, even maybe stepping higher than that above the banking sector, the regulation of banks is supposed to be an objective, partially subjective, but objective safety and soundness practice. It is not supposed to be a policy vehicle for value judgments or for ideology to express

its viewpoint. And we have a system in the United States where political accountability is supposed to be built in to policy decisions. And when you start getting into more of the, you know, regulatory apparatus of independent bank agencies, that really starts to go away pretty quickly. And so, you know, there do appear to be a lot of questions. I think Nick raised a lot of strong evidence. There appears to be a lot of smoke. And I think the American public and certainly the crypto industry deserve answers to those questions. Yeah. And just to fill in some of the details that I heard from another source who has experience in both TradFi and Crypto, I'll just call this person X. They said of their experience working at a crypto company, we were told by a bank, no guns,

no cannabis, no crypto based on the direction they had received from their regulators. And X also And this kind of fills out something that Nick mentioned said that. Some banks are required to file CRAs, which are crypto-related activity reports monthly. And then drawing on X's Tradfai experience, they said, I know how it works. I've been in the room with the OCC when they squeeze banks. They have very punitive tools. Stress tests for the globally systemic important banks, G-Sives. These include qualitative and quantitative tests. They will require incremental staffing, reporting, etc. for, for instance, banks that continue to serve as crypto companies. And so one example would be like they would force that bank to have a higher minimum of regulatory capital per unit of, you know, like crypto industry deposits or like exposure to crypto. And then so their assessment was if it's a new industry and has limited revenue, they will kill you with overhead to make it very unprofitable, you know, for instance, like requiring these

CRAs. And then they noted that this is kind of being incorporated. into the Basel requirements, which are, you know, big requirements on banks. And they sent me a link, which I can include in the show notes. But I kind of took a look. And from my understanding, there's like what they call group one assets in group two. And group one is tokenized real world assets or kind of more conservative stable coins. And then group two is all other cryptos and then sort of like riskier stable coins. And group two obviously has like much more onerous if you have more exposure to that,

then that has more onerous requirements. You know, this person's assessment was, if you're a senior banker, you spend most of your time trying to optimize reg, regulatory capital and returns on regulatory capital. For crypto, they punish you by making reg cap very expensive. So, and then, you know, like Nick's set, they added, of course, then it's harder you.

Even if you get a bank account, it would be super hard to get things like a loan. Yet, I don't know if you wanted to add on that, but I just wanted to, you know, because it is a leap to, like, say, okay, this is happening. I mean, we can sort of see this trend. But now, you know, just the more voices that we have on this, I feel, the more it kind of fills out the picture. Well, yeah.

I mean, I think, I think to put a finer point on that, and I think this is accurate. I haven't looked at it for a little while. But I think the Basel Committee came out with a 1,250 percent risk rating for crypto assets, which. That was the category, too. which added, you know, an 8% capital, you know, requirement equates to a dollar for, it equates to a hundred percent capital requirement. So it equates to holding dollar for dollar against, you know, any type of crypto asset. So banks are a business. They don't do things for free.

They do have to maximize regulatory capital. And I have always felt that, you know, some of the seeds to the next financial crisis are laid in the regulatory, you know, constraints of the present day and how that creates, you know, management issues and incentives that steer activity towards the most advantaged regulatory products. And that's where all of the interest goes. And then you leave things that have massive potential innovation benefit behind. Yeah, I'll just add to that. I mean, the red cap question, that's a very explicit way of raising the cost.

But frankly, most banks don't want to hold crypto directly. I mean, a lot of what we're talking about is simply banks doing business from a Fiat perspective with firms that touch blockchains or their software providers for the crypto space. And there's implicit costs there. So certainly what bank executives are telling me on a widespread basis is if you are engaging with crypto depositors, you just fundamentally face more scrutiny, higher demands for more stepped up, AMLKIC requirements, and more frequent and burdensome data requests. So it's my understanding now that the FDIC does make these crypto-specific data requests

on an ongoing basis with that began in about Q4 of last year. So if you think about it, if you're a smallish bank and you're not exclusively focused on crypto, which is the case today, there's no banks left that really have crypto as their sole purview, it becomes very costly to have sort of 10 or 15% of your book be crypto-related. Because you have a higher fixed cost, you're considered to be sort of a higher-risk institution or you're facing a higher-risk industry. And those costs are almost not worth it at that point because the revenue you're earning from crypto, if it's a smaller share of your depositor base, is less. So it's kind of a bit of a catch-22. I know the Fed says they don't really want banks to

have depository bases that are correlated. But if you're a smallish bank and you only have 10, 15% of your deposits that pertain to the crypto industry, the costs almost become not worth it. So it's a bit of a catch-22, the combination of those two things. Yeah, that's an important point, Nick. There's a lot of soft power, an immense amount of soft power that a bank examiner or the bank regulatory community has, you know, through things like paperwork requirements. All of a sudden, and I've heard this directly from a, you know, a senior executive at a globally systemic important institution that if they were to take on any crypto business, the sheer amount of paperwork that they would have to complete just does not make it worth their department's time.

So there are ways to not prohibit it, but effectively, you know, disincentivize it to the point where it is, you know, no longer, you know, bankable. Yeah. And so a lot of these things are, yeah, just different ways to kind of pressure banks to not deal with crypto companies. But I did want to also highlight something from the National Economic Council statement back in from January 27th, which says, quote, legislation should not greenlight mainstream institutions like pension funds to dive headlong into cryptocurrency markets. In the past year, traditional financial institutions limited exposure to cryptocurrencies has prevented turmoil and cryptocurrencies from infecting the broader financial system. It would be a grave mistake to enact legislation that reverses course and deepens the ties between cryptocurrencies and the broader financial system.

So, you know, between what we've been discussing, like some of that is sort of behind the scenes. And then this part is just sort of explicitly being like, don't do it. So there's so many directions we could go from here. Well, Laura, I mean, you know, let me just chime in there. I mean, I was at the CFTC in March of 2020 when there was a massive dislocation in the treasury markets, supposedly the, you know, most deepest and most liquid markets in the world with the most, you know, secure, supposedly risk-free asset. And at the same time, you know, the most deepest and most liquid markets in the world, at the same time, the price of oil in the futures market went negative. So, you know, we do live in a world where volatility exists and it expresses itself in a number of ways, in a number of different

products and venues. And the point cannot be to eliminate risk from the financial system, because then you eliminate the financial system. And people can answer for themselves whether or not that's their true goal. But the point is to appropriately manage risk within the financial system through the tools that we have that have come to evolve. Yeah, and if I may add, prior to the current banking crisis, there were a lot of statements from various regulators that, similar to the NEC statement there, that they wanted to insulate the traditional financial system

from the purported risks of the crypto space. But if you look at the ultimate causes of the bank crisis that we're now experiencing, crypto is not the cause, right? there had been worries that perhaps stable coins would perturb the treasury market if there was a run on a stable coin, all the treasuries were sold off. That was one of the worries. There were also worries that there was concentration in the banks that focus on crypto and that that might cause a financial crisis. But really, from my perspective, the ultimate cause is simply whipsawing interest rates, interest rates that rose really quickly and cause the value of the assets that the bank. conventional banks were holding to fall. And then combined with some of the liquidity risks that, for instance, we saw with SVB, with the flighty depositors. But this is like a global problem. It's not confined to crypto. The banks that are now imperiled credit sues didn't have anything to do

with crypto, for instance. SVB had, as far as I can tell, one crypto client. So the ultimate cause of this bank crisis is not a crypto thing. But the regulator sure gave it a lot of airtime. the idea that the risks from crypto could somehow, in fact, the traditional financial system. But that's not where I would sort of apportion the blame for this current crisis. I agree with that. I mean, look, the banking system exists solely because of confidence in it. If everyone rushes to a bank and withdraws their money, the fractional reserve banking system cannot survive, which is why you have a regulatory structure designed to prevent bank runs and

ensure confidence. And it was no accident, I think, that as Silvergate was running into difficulties and sold through, you know, their treasury, you know, security portfolios and took on a huge loss. Now, I think we can debate whether or not that was actually the best decision as opposed to doing something else with it, like going through repo. But, you know, in realizing that loss, it's probably crystallized in a lot of people's minds. Well, geez, if it can happen to that bank, and they have to sell securities and they're going to take huge losses. Where else could that, could that happen? The point of regulation is to prevent panics. And unfortunately, regulators acted, you know, after that panic had occurred. So Silvergate received a $4.3 billion loan from the

Federal Home Loan Bank of San Francisco. For reasons unknown, they decided to pay it back in full just days before it shut down. And I think you guys probably saw that article in CoinDesk, where a spokesperson for Silvergate told CoinDesk, FHL Bank, San Francisco, did not request or compel Silvergate Bank to prepay its outstanding advances. Silvergate made their determination to prepay their outstanding advances based on their own assessment of their position. So this is confounding to me. What do you think happened there? Did Silvergate make a mistake in their risk assessment, which then caused them to shut down just a few days later? Or do you think they're kind of hiding what happened about having to pay it back?

Or what do you think happened there? I mean, you're right to zero. And on this, this is one of the two main catalysts for the dissolution of Silvergate, and there's enormous open questions there. So the FHLB denied that they explicitly compelled Silvergate to repay the loan. But it's absolutely the case that there was a very active

political pressure campaign against the FHLB. When it became clear that Silvergate, was using that facility to honor their withdrawals. So it would not surprise me if Silvergate was considering that and realizing that they perhaps could be imminently cut off from that facility. It was also a short-term rolling facility. So a non-renewable, non-renewal is tantamount to forcing them to pay back the loans. But you're right, because that was the decision that basically precipitated their liquidation.

And so a bank doesn't just commit suicide like that. So I think there's still enormous open questions as to what specifically happened there and whether the political pressure that the FHLB was getting contributed in any way to the paying back of the loan. I think I would just say what I had said before, which is, look, there are a lot of questions here. The longer those questions go unanswered, the longer a lack of confidence is going to remain in both either either the motivations of the parties involved or in the solvency of any individual institution, if you're just a retail participant and reading the front page headlines. I mean, the one thing I would say about Silvergate, and this also applies to Silicon Valley,

is I think that what happened with both of those things demonstrates how important it is to diversify your clientele because if an industry gets affected in one way or another, or there might be similar behaviors or characteristics among that clientele, which would expose you to more risk. So that's just one thing, but I don't think it's necessarily, it doesn't have to do with what we just said so much as just a general banking best practices type of comment. But I also wanted to talk about signature because that was another one that is very confusing because obviously First Republic was in a worse situation, but that one was able to get saved. And, you know, with signature, it sort of seemed to be preemptively closed. And I know, Nick, you've talked at length about what you think the irregularities are there. Actually, one thing that I do want to note for people who listen to the show with Caitlin Long and Meltem is that, Milton de Mirrors, is that I was not aware of this at the time we recorded. It turns out technically it is legal for the New York Department of Financial. services to put a bank into receivership if they feel that they're not getting good data, which is

interesting to me. It doesn't seem like that should be possible in my personal opinion. But I did want to correct that fact there because it didn't occur to me that actually was legal because it just sounds like it shouldn't be legal. But Nick, can you elaborate a little bit on what the irregularities were with signature? Sure. Yeah, you're right. The New York banking law is extremely broad with the set of conditions that would render it permissible for DFS to put a bank into receivership. And that is one. So DFS noted a crisis of confidence in leadership and insufficient data as their primary justifications for putting them into receivership. I think that situation needs to be looked into, absolutely, because if Barney Frank, who is on the board, a signature of his

allegations are true, then it's very unusual to have a solvent bank put into receivership. I'm not sure I could name another example in U.S. history when that's happened. The timing is odd as well. SVB was closed on Friday afternoon. Signature wasn't until Sunday night. Typically, it's done on Friday and then there's the weekend for the FDIC to try and shop the assets or arrange an acquisition to basically close it in an orderly fashion. That didn't occur in this case. You have Barney Frank's allegations. And then, frankly, you have the treatment of the crypto deposits at Signature, where

ultimately the buyer of Signature did not assume either Cignaut, which is their Fiat Sett settlement network, which was the biggest of the two between Sun and Cigna. and they did not assume the crypto deposits. The crypto deposits were the FDIC told crypto depositors, and by crypto deposits, I mean Fiat deposits of crypto firms that were clients of signature. The FDIC told them to withdraw. They're remaining $4 billion. So that portion of their business, which was a very material part of Signatures business, was ultimately not included in the sale to NYCB, I believe it is. So, you know, that's an open question. Like, you know, on one day, this is a crypto-focused bank, or at least crypto is a meaningful

portion of their business. And then they're put into receivership. And then through the acquisition, the assets that are sold include no crypto element whatsoever. So if you wanted to ascribe an anti-cryptomotive to the receivership, that point of evidence would strongly support that conclusion, I think. So we've kind of alluded to this as being something that appears to be coordinated, at least in the banking sector. But at the same time that all this is going on, we are seeing enforcement actions from the SEC against, for instance, Krakken and Coinbase, and then CFTC obviously had its charges against finance. And so when you see kind of what's happening across these different agencies, I wondered if you thought that this was a

generally coordinated crackdown on crypto across government agencies. Because, you know, it sort of looks like that from the outside based on the timing. But then I also see people joking or surmising that government agencies either don't really cooperate with each other or don't do so effectively. You know, people point out how the SEC and the CFTC are sort of at odds over whether or not cryptos are securities or commodities. And Brian, I wanted to get your opinion on this since you used to work in the government, you know, what's your take? Like, is that a conspiracy theory to think that this is a coordinated crackdown or is that plausible? So, right, Laura, I was a commissioner at the CFTC from 2017 through 2021 and I was there when the futures contracts on Bitcoin and

ETH were listed on CFTC registered only exchanges. And they are still listed on CFTC only registered exchanges. So the status of those products is at this point, I think, you know, it's not necessarily in doubt. If the SEC views any product as a security, then they can take actions to, you know, overtly declare that. They can ensure that those contracts are taken down from CFTC registered exchanges. You know, they can file actions against individuals trading those contracts. So none of that has happened. So despite a lot of the language that we're hearing that appears to be creating deliberate vagueness, to me, the status of those two products is crystal clear. In terms of your question around, you know, a deliberative, a deliberate coordinated approach. Maybe I'm biased from working with the

CFTC, but I see a very strong distinction between, apart from the timing, which I don't know what to make of, but I see a very strong distinction between the CFTC's case against finance and the settlement against Cracken, as well as the seven-line Wells notice that was submitted by the SEC to Coinbase. You know, the CFTC's complaint stretches back three and a half, four years. It has very detailed text messages, recordings, other kinds of documentation, transcripts around conversations that really seem to allege a deliberate attempt to evade U.S. laws while also showing an overt attempt to cater to U.S. customers, you know,

for a platform that had direct compliance obligations, especially in the derivatives markets. I mean, the derivatives laws are very clear. You know, this is, this is not, you know, a subjective how we test where people can go and, you know, take one prong and then wave it around and say everything's a security. And the derivative laws are very clear about what derivatives are, and that if they are offered to U.S. customers, there are certain registration obligations that have to be followed. Those were not followed in this instance. And they also then created BSA obligations, bank secrecy act obligations on Binance.com, which again, according to the facts that were alleged, they knew about and deliberately tried to work around.

So this feels like a very, very strong and clear case that the agency has brought. And I think, you know, from our perspective, you know, and I know, Nick agrees with this in terms of someone that's been so vocal about the potential of this technology. We believe in the world computer aspect of this innovation, not the world casino aspect of this innovation. Unfortunately, it's been hyper-financialized. And I think you can see that also in some of the examples shown in the Binance case, alleged in the Binance case. Binance offered 125 times leverage on some of their products, that wouldn't be allowed anywhere in the U.S. derivatives markets no matter basically what you're trading on. And they also had, you know, games and contests where, you know, traders could

compete over the course of one minute to see who, you know, made more or lost less in derivative market transactions. I mean, this is not where this technology and this innovation was meant to achieve. This was someone looking at it from the most financialized aspect possible. And unfortunately, creating a bad name for the ecosystem. Yeah, or like gamified. It feels like video game type stuff, like leaderboard type stuff. Yeah, yeah, absolutely. And so I think that there is a completely different promise to this technology.

And I think the sooner we get back to that by ensuring that exchanges that are fiat on and off ramps into this ecosystem are complying. and I think Coinbase is a great actor in this ecosystem. They spend a tremendous amount of time and resources on compliance. They're a publicly traded company. And again, to me, in my mind, you know, a vague Wells notice issued by the SEC that could portend some kind of enforcement action to them stands in complete contrast to the very detailed and clear case that the CFTC is bringing against finance. So in a moment, I would like to ask you a follow-up question.

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So if we were to leave aside the CFTC case against finance, which you're right, it's 70 pages and there's quite a number of damning text messages and other things in there. when you look at least at the other actions, we talked about the SEC and then Operation Choke Point, some of these statements from the administration, does that look coordinated across agencies to you? So the intent or possible outcome of that activity looks very similar. And I think, you know, it's reasonable to ask yourself or anyone to ask themselves or to ask, you know, the SEC, why has there not been updated guidance in this ecosystem for

for the last four years, when legacy rules cannot fit the way this technology works and do not apply and whose underlying rationale, you know, aren't applicable to the motivations of anyone that is purchasing a number of these tokens or the way that a lot of the software is being constructed. You know, it's reasonable to take the view that if, you know, if no new guidance is being issued and only enforcement is being used is the only tool to address the space, to go after the space and express a view that is not clear. You know, is that really appropriate? I mean, is that is that what the securities laws were meant to do?

And I think that there are a lot, again, there are a lot of questions there. I think there will be a lot of questions about that in Congress. And I don't know the quality of the answers that we should expect. I think what that does mean is that it's an extra motivation for Congress, and I think it's a strong one, and I think they're hearing it, that the solution lies with them on how to construct something new that does respect this technology, that does respect consumer protection, you know, that brings a lot of the aspects here into a regulatory fold that is designed appropriately, calibrated thoughtfully. and I'm hopeful that we'll see that, and I'm hearing positive things about that. Yeah, no, I'm broadly aligned with Brian's thinking on this. Frankly, I think the SEC, it's been clear what their objective and agenda is with regards to the crypto industry for years now. So I don't see any necessary change or discontinuity there.

They have maybe become more aggressive recently. But this seems like the ordinary course of business for them. on the banking front, I'd certainly see coordination. So I wouldn't necessarily tie the actions of the Fed, the FDIC, and the OCC to those of the CFTC and the SEC. On the banking front, I do see a C change starting with the collapse of FTCX, where I believe the banking regulators decided that they needed to use the tools at their disposal to start to limit the access of crypto firms to the traditional banking sector. And certainly when you see an interagency statement covering the Fed, the OCC, and the FDIC, that obviously implies a degree of coordination. And when you have the National Economic Council releasing a statement on the same day

as the custodia denial, for instance, that clearly implies some coordination. I actually don't think it's the Biden administration's sort of top or even top five priority to marginalize the crypto space. But I do believe that now that Congress is somewhat hamstrung or at least divided between the two parties, the financial regulators, especially banking supervisors, realize that there would likely not be congressional action to stymie crypto for the remaining two years of Biden's term. And I believe that post-FTX, they effectively decided to take it upon themselves to limit the reach of the crypto space and certainly limits, limit its ability to, quote, unquote, infect the traditional banking system.

So, yeah, no doubt in my mind that, at least with what's called chokepoint 2.0, that is being coordinated on a cross-agency basis. Yeah, so two other notes on this that I want to point out are coin desk came out with an editorial saying that it looked like there was an attack on crypto by the government. and then Cooper and Kirk, which is a law firm that had, I think, sued the government over the first Operation Chokepoint did release a white paper kind of collating a lot of the information they had and saying that this was an Operation Chokepoint 2.0 directed against the crypto industry. One thing before we move on to what I really feel is quite possibly the biggest outcome here, which I think is more in the geopolitical realm, is, you know, let me summarize a little bit what I think you guys are saying and then we can talk about it. It's that you feel that there needs to be smarter, either legislation or guidance from agencies rather than sort of cryptic enforcement actions or punitive ones that don't

kind of allow people to follow any rules because there aren't these rules in the first place. but that some of these actions are legitimate, for instance, maybe the one that the CFTC is bringing against Binance, and that some of this also is potentially like an overreaction against FTCs. Is that a good summary of your thoughts there? Yeah, I guess I might just add a little bit more to that, which is that the lack of clarity here forces good actors that are intent on trying to comply with some vague standard to be ultra-conservative,

which then highly advantages, you know, overseas activity that is not necessarily, you know, motivated that could be adversarily motivated, and really disadvantages the development of that ecosystem here. The best way to disincentivize illicit activity abroad is to have to have a robust ecosystem here in the United States. And I think that goes for the derivatives markets, too. I mean, we have the most liquid, most transparent, most robust derivatives markets here in the U.S. And I don't think it's a coincidence that we also have, you know, the strongest economy, usually in the world. We only have two derivative products that trade because of the lack of clarity of the status of these tokens. We have derivative contracts on ETH and we have derivative contracts

on Bitcoin. If you want to trade any other derivatives contracts, use them for risk management purposes, which is the foundation of the derivatives markets, you have to go overseas. So the way that you develop more incentives to stay here and more disincentives for those operating illicitly abroad is to provide the clarity which has so far been missing. I agree. I think we could certainly do with more clarity regarding spot market regulation and just who oversees the markets and the framework there. And of course, on the securities front, we have no framework whatsoever for how for a common sense disclosure regime, for instance, for token issuers. And I don't believe that the legacy securities regulation that we have here is fit for purpose. So much work to be done there.

And I think that's in the hands of Congress. On the banking front, it's slightly different. I mean, I think we basically have a violation of due process. I would say it's primarily a Fifth Amendment issue where these regulators are taking it upon themselves to determine who the banks can and cannot deal with. That's a vast overreach. That's not their mandate. Their mandate is to ensure the soundness of these banks. It's not to pick and choose what industries they can serve. So I consider that a significant overreach. And of course, the net effect of that and the prior thing is that crypto firms are increasingly looking abroad for new homes or they're looking for more crypto-native solutions. So instead of holding their funds of the bank, maybe having their balance sheet in stable coin format.

So I think the U.S. benefits from being the world's home for securities markets. The U.S. is something like 25% of global GDP, but 40% of global public equity capitalization. And that's been a huge benefit to this country historically. So I do think they'd be squandering that advantage as they continue down this path and discourage crypto firms from domiciling themselves here. between the outright hostility that we're seeing on the banking front and then either the lack of guidance or outright hostility, you could call it from the SEC, all of this basically makes it difficult for entrepreneurs in the U.S. And I wondered if you felt that the government was taking

these actions almost because crypto could pose a threat to the U.S. dollar or to the U.S. financial systems. And if so, you know, how you thought that would play out. as the technology develops and if this trend continues of entrepreneurs moving offshore. I mean, I certainly don't believe for myself, I don't believe crypto is a threat to the dollar at all.

I mean, what we actually see in the crypto space is the dollarization of the crypto industry. So initially, Bitcoin was the sort of medium of exchange and unit of account in crypto and increasingly became dollar-based. The collateral and smart contracts is primarily dollars.

I mean, when you, when you have a contract that has some long duration, you want it to be denominated in dollars. You don't want to take on the exchange risk. So stable coins have infected the crypto space, not in a pejorative way, but they are increasingly the dominant collateral type and medium of exchange in crypto. There's more value settled in stablecoins than there is in Bitcoin or ether. Stablecoins have a higher velocity than those crypto assets. And 99% plus of all stable coins globally use the dollar as their unit of account. That's far, far more than the dollar's share of international trade or of foreign exchange reserves, right? So the other thing

is, of course, crypto is a vector for proliferating the usage of the dollar globally. It's a way to give people effectively U.S. bank accounts in places where they would never have that access otherwise, right? So it spreads the property rights associated with the U.S. dollar banking system globally. And I think that has a huge welfare benefit to people in emerging markets with unsable currencies. And of course, if you look at the data, you see the places the highest adoption of crypto are Southeast Asia, West Africa, Eastern Europe, Latin America. In certain places, you have weak property rights, poor governance, not a lot of rule of law necessarily, and maybe a banking system that can't be trusted. Those are the hotspots of crypto adoption. So that tracks

with this idea that the exporter property rights is part of the appeal. So I think there's a tremendous opportunity to embrace the notion of a stable coin, which is just taking the assurances we have of physical cash and digitizing it. But there's so much opposition to that in this country. In January, one of the things that really made me set up was the Fed basically said, we don't want banks issuing stablecoins on public blockchains. They effectively banned that. But it would be better if banks could be the ones issuing stable coins, as opposed to just private

firms. It's unclear now what that pathway is going to be to take the existing stable coins and make them even more credible and give holders even better assurances. The various trust companies that issue stable coins are sort of imperiled. So I think it's very clear that stable coins, especially dollar-based stable coins, are one of the key products that the crypto industry is creating, one of the key killer apps of the space. And there is certainly a risk that the crypto space, you know, becomes dominated by some other sovereign fiat, like euros or, you know, whatever it is. So that would be a tremendous shame if we lost that advantage. Yeah. And just one comment I'd like to make on that is that one thing that surprised me so much when I wrote my book was that when I was interviewing

people who were European or Asian or whatever, they would always quote the price of Bitcoin or ether to me in dollars, no matter what their home currency was. Nobody ever quoted it in their actual currency. And these were, by and large, foreigners. And that was just something that struck me. It was very fascinating. But, you know, just from that alone, you know, I interviewed like more than 200 people from my book, just from that alone. Like, it definitely felt like, yes, it's getting all these people who don't live in dollars to think in dollars and transact in dollars, which was fascinating. If you reduce the friction in foreign exchange markets, and now people can go to their exchange as opposed to using some sort of Western Union or money gram or something,

a lot of these people literally have no ability to hold dollars in any other format. They certainly don't have access to PayPal or Venmo. Then the dominant currency actually grows its market share. That's what we've seen empirically. Not to mention the fact that the U.S. does need new buyers of treasuries. Foreign central banks are divesting treasurer. There's a lot of net sellers of treasuries out there. Every time you buy a stable coin from one of the credible issuers, that ends up being expressed in the form of treasury exposure. So there's also that angle. There's $130 billion, give or take, worth of treasuries than are being held by these stable coin issuers. That's also a benefit I would point to. Yeah. I mean, I think Nick put it so well, and I think to summarize that, I see a lot of deep thinking that reflects, the benefits of crypto and stable coins to the dollar. And I do not see a lot of deep thinking or

analysis that reflects the threat that crypto and stable coins can have to the dollar. So is it possible people have those views? Yes, it is. I haven't necessarily seen a very strong rationale for why they hold those views. But they do seem to be prolific within the central bank ecosystem. One of the steelman cases maybe against stable coins is the U.S. loses the ability to pursue sanctions, but I just don't think that's true, right? So if you were to encourage a network of onshore stablecoin issuers, all stable coin issuers still have the ability to determine who is using the network, especially with regards to creation and redemption, they have the ability to freeze tokens on the network. So it's not like you're just throwing the currency of the wolves and

creating this totally anarchic system. I mean, the stable coin issuers still have discretion over who is using the network. So I think you retain your sanctions making ability. If that is the objection to stable coins, if you discourage the growth of the onshore stable coin market, you empower the less accountable sort of crypto euro dollar stable coin issuers that are not doing it onshore. So tether has been a huge beneficiary of all the recent events in the crypto space as people have basically started to realize that there might be some risks to staying onshore. Of course, USDC was affected to a certain degree by the SPB issues. And a lot of folks have shuffled around their balance sheets and now are holding tethers instead.

that can't possibly be something that the financial establishment the U.S. is happy about. I mean, Tether is completely unaccountable to them. So if you discourage local stablecoin issuance, people still want stable coins. They'll just do it with a less transparent and less accountable entity. Yeah. And playing into all this, of course, is the recent news that Hong Kong is going to be issuing, clarifying guidance on, you know, crypto assets over there. And at the same time, it appears that this has the blessing of China and that even, you know, crypto companies are finding that they're getting banking relationships over there.

So if this continues in this fashion, then, you know, how do you see kind of the U.S.'s attitude toward crypto affecting these geopolitical issues and perhaps even the status of the U.S. dollar as the global reserve currency? I think what's going on with Hong Kong, I mean, as you say, it appears to have the implicit backing of China. But yet that in and of itself is somewhat strange that Hong Kong, given the dynamics that we've seen there over the last few years in coming under Chinese rule

to express themselves that in that way, contrary to kind of the dictates that exist in Beijing, is just a very strange dynamic. So you can't help but think that there has been some level of blessing of that. of that process. Maybe they're creating sandboxes in Hong Kong, right? Maybe they're trying to figure out how to attract development so that they can crowdsource a lot of that innovation. Maybe they want to end up using it for say purposes. Maybe they want to try to understand how they can better infiltrate the digital yuan into the kind of the crypto ecosystem or into kind of the next

web three economy. I mean, it's, it's, it's easy to speculate on a lot of different kinds of things. And it's hard to kind of figure out. The thing that worries me is that when we kind of bring up the China aspect in Washington, there are a lot of people that then use that as an excuse to advocate for a U.S. Central Bank digital currency. And there are so many policy issues that need to be addressed, very difficult policy issues that I think may be hard for, you know, Congress to achieve consensus on before a central bank digital currency could even be issued, that it feels like it's a distraction. I would rather kind of focus on the advancement of the technology and who's going to own the next set of that innovation. Who's going to own the tools of Web 3? Who's going to be

the home of kind of that innovator community? Where is that legal system going to be based? Where is that academic research going to be based? Where are the universities going to be located that attract that kind of talent. Where is the funding community going to be based? You know, where do, where do Daos locate with appropriate legal protections? And where do their treasuries then have the ability to pay taxes and hire third-party service providers? I mean, to me, that's more of the geopolitical issue from the United States, which is, given the trajectory we're on, you know, sure, maybe China can make some advancements. We risk losing, you know, that amount of innovative, intellectual capital to basically anywhere.

Yeah, almost like if we had Silicon Valley along with Amazon and Apple and Netflix and Facebook and Twitter and yes, of course, I think some of some people view some of these companies as problematic or that they became so eventually. But there's no doubt that there was a huge amount of capital and value and jobs. And yeah, there were a lot of benefits. I think, to having that located here. And this is not only technology, but also financial markets that we're, you know, building in the space. Then, yeah, both of those things could potentially go offshore. So in a way, you know, because I phrased my question as being about money itself.

And you're saying, well, it's really about these centers of technology and innovation. Is that right? It's possible. It's just hard to speculate, you know. I'm not going to pretend to have a crystal ball to understand what the Chinese Communist Party is thinking or what that relationship is between them and Hong Kong and how this is trying to play out. But I think it's certainly a risk and I think it could be a motivation. Yeah. And at the same time, we are seeing that China and Russia are trying to do more of their own economic transactions, not using the dollar.

So Nick, so what are your thoughts now for all of this in relation to, Bitcoin because we did see that biology, Srinivason had some strong thoughts on that. And I was curious to hear yours. I think, frankly, the Bitcoin narrative has been strong. Of course, you know, Bitcoin itself has left to say your position themselves as an alternative to the fractional reserve banking system. I will admit, I'm one of the bitcoins that supports fractional reserve banking. I think it can be done prudently. And I think there's plenty of historical examples. We've never even seen a historical full reserve banking setup that was a market determined that actually existed. So, you know, all banking historically is fractional reserve.

And I think credit creation is good for society. I think the main reason Bitcoin's been rallying is simply that the Fed, in response to the banking crisis, adopted a more accommodative posture. And their balance sheet started growing again, and they started injecting liquidity into the markets. So that's an exogenous variable to crypto. I would causally ascribe that the bulk of the explanation. Certainly, I think they're going to face further issues trying to restore the confidence in the U.S. banking system. I don't know if an unlimited depository guarantee is a solution, but it certainly does

betray the fragility of our current banking system. And I think it implies for the liquidity injections down the road. So I would say that's the main reason Bitcoin has been rallying here is not any endogenous crypto factors, but simply the broader liquidity environment. I don't think that's conducive to a million dollar price, though, unfortunately. Brian, what were your takes on his bet, which was that the U.S. dollar was going to, sorry, that the price of Bitcoin was going to reach $1 million in 90 days because there was going to be hyperinflation in the U.S.

Yeah, I mean, it's interesting, you know. there's some level of entertainment. It's very diplomatic term. The level of debt in the United States has skyrocketed over the last, you know, pick your term, you know, one year, five years, 10 years, 20 years. And, you know, right now we're over 100% debt to GDP. I think it might be up to 120. You know, that bill comes due at some point. You know, people want to hold dollars because we have a very strong economy.

we have relatively stable monetary policy. You look at the level of indebtedness of a lot of top economies in the world, and it is astounding. And we also have a government process that kind of advantages deficits deficits. You know, we have a process called reconciliation in the Senate that advantages tax cuts when one parties in charge and advantages incredible amounts of spending when the different party is in charge. And, you know, I understand both of those meet the philosophical needs of those parties, but compounding that over time does not, you know, it starts to spiral into a pretty big problem.

If the economy is not spurred faster, you know, then those things add to the deficit by either of those actions. And so, you know, that could be coming at some point. And we'll see. The loss of confidence in smaller banks, which is what's happening right now, of course, we see deposits flowing to large banks and then go to treasuries directly, that is actually deflationary, in my opinion, because it is those small and medium-sized banks that do the bulk of lending in the economy. Small banks lend to small firms.

and if you lose that, you lose a strong driver of money creation and GDP growth. So I actually see it being a drag on the economy and destructive to the money supply, the dynamics that we're seeing in the bank sector. Longer term, of course, the existence of the debt as it is, is an inflationary thing because no one's going to adopt austerity. and we're certainly not going to default. So the only choice there is an inflationary reset. So I do think people need to be prepared over the next decade or so for a structurally higher inflation environment.

But in the immediate term, I actually think the issues the banks are facing is somewhat deflationary. So now we've outlined all these different things happening to crypto companies in the U.S. At this moment in time, what do you think is kind of the best recourse for them? what activities are they doing that you feel maybe could lead to good outcomes eventually? Or what sort of gives you hope? Well, regarding the sort of repression happening in the bank sector, I'm seeing crypto firms just redomiciling. That's actually pretty hard.

It's easier said than done, especially if you're a citizen. I'm seeing some firms adopting more crypto-native expression. So they are just choosing to have their balance sheet be on change. and maybe held in a multi-sig and using some of the great tools that exist to manage their corporate treasuries, which is a pretty interesting solution. And some are just hunkering down in the U.S. and hoping for a change in the administration or something like that. As far as recourse is concerned, there's some interesting initiatives underway where there's potential litigation. As I said before, I think being unfairly deprived of your banking relationship because of the industry that you're in

is a violation of due process. And there may be some recourse there. Those were the lawsuits that were lodged around chokepoint 1.0. And I think I certainly know there's interested firms that are trying to prepare that type of litigation. So that would be one thing. And frankly, I think Congress has a role to play in terms of their oversight. There have already been hearings pertinent to the choke point issues that we're seeing. The first time around Congress did play an important role in servicing valuable information and bringing these regulators actions into the light and placing a check on their behavior. And of course, Congress is the entity that has been, and the regulators have been sort of usurping their authority to a certain degree. So I think there should be a reaction in

Congress. And thankfully in the House, we do have some folks that are really attuned to these issues and do appear to be reacting. So I would say as far as the bank situation is concerned, those are the two main channels that I see is litigation and then more congressional oversight. Yeah, I'd agree with both of those. I mean, I think litigation is a critical tool when you believe the government is overstepping its authority or not being transparent as how it's operating or as imposing value judgments through non, you know, non-political process means. And as I said before, there are a lot of questions that need to be answered and maybe that's the best way to answer them.

Congressional oversight should happen. I think it will happen. I think other areas of recourse are, there are, what, you know, 20 million people in the United States, maybe more that own crypto. every single one of them has one member of Congress and two senators. I've worked in a congressional office before. They read the mail. They read emails.

They answer the phone. You know, they should be calling if they care about, you know, the future of this technology and the ownership over, you know, those tokens. They should call and write their members of Congress and their senators and say, it's okay and probably good to regulate crypto and protections are fine, but don't ban this technology. there are use cases for this and I'm a proud owner and I see the potential benefits of this. And the last thing I think that gives me hope and I think it's stronger than hope. It's at some level of belief and it's to Nick's point that there are informed members of Congress in positions of authority that care about consumer protection that are not just blind advocates of crypto that are working.

hard and cooperatively across the aisle to develop legislation that can bring some rules of the road and some clarity and so much lead to clarity to this space. Because otherwise, the other, piece of hope and belief that I have is that there are foreign jurisdictions. The UK is a prime example that are much more thoughtful and well calibrated in the broader messaging of the entire government than what we're seeing here. And that, well, they're still working through some of the issues. They are proposing frameworks that appear to be very thoughtful. Their language is very thoughtful. It's very well calibrated. It describes the fact that there may be risks to this new kinds of technology, but they are likely different. And there

needs to be similar regulatory outcomes if there is similar activity that's involved, as opposed to just saying that there are same risks if that activity exists, and therefore there need to be the same rules, regardless of the consequences to the technology. So I think there are a little. lot of opportunities to have hope or belief in, you know, positive outcomes here. We'll see which comes online first and what happens in the meantime. And then I wanted to ask about the CFTC lawsuit against finance versus the SEC's assertion that everything except for Bitcoin is a security. And I wondered if you thought that there was a potential for that to be sorted out within the next two years, say like before the next administration. It

could potentially be sorted out by the judge in the CFTC case because they would have to first determine if the CFTC has standing. And since the CFTC said in the lawsuit that Bitcoin, ether and like coin and two stable coins are commodities that that would have to be determined first. And I was curious if you thought that that was going to happen kind of on a faster timeline than some of this other stuff might happen. I don't, I don't think that. that is in doubt legally. It may be in doubt linguistically or politically. Wait, what do you, when you say that, but I mean, the SEC keeps saying other cryptos besides Bitcoin or securities, or at least Chair Gensler does.

Well, I mean, I think the, I believe that there's clarity around ether specifically, because contracts, futures contracts to river's contracts on ether have been trading on CFTC, only exchanges for the last four years. So if the SEC viewed that as a security seriously, then those exchanges, the CME group, for instance, is violating the securities laws. So they would be facing an enforcement action or they'd be told to delist the contract. That contract is up and is continuing to trade. So then how do you view Chair Gensler's statements that everything about Bitcoin is a security? The actions of the agency don't match that rhetoric. In terms of of their ability to enforce that view by telling CFTC registered only exchanges that they would need to delist those products because they viewed them as securities.

Okay. Interesting. Okay. It seems like you're saying that no matter what Chair Gensler says that the way the agency has been acting these last four years is that Ether is a commodity. Is a non-security. Yes. Yeah. Okay. Non-security. Yeah. Okay. Non-security. Yeah. Okay, so you're saying it's a settled matter. The SEC can always bring a case against somebody on anything at any time. You know, they could say Bitcoin's a security, you know, at a turn of a switch. And unfortunately, that's the way, you know, the securities laws work. And that's the way that they have ensured that they can respond to updated facts and circumstances as things evolve and change. There's a rationale for that.

But as it stands now and as it has stood for the last four years, both Bitcoin and ETH are non-security commodities. And then would a further extension of your statement be that with this Wells notice, when Coinbase responded that a number of the offerings that the Wells notice might be referring to were ones that were listed in its S-1 back in 2021, are you saying that that would be a good argument for Coinbase, that that would then be a way that they could push back on the SEC? see? Well, I see them as basically separate issues. You know, I was talking about the status of ETH as a non-security commodity because of its current regulatory treatment, you know, in the

regulatory community, which is that if it was viewed as a security, it would have to trade under a different regime than it is currently trading now. In terms of the Coinbase Wells notice, there's not a lot of detail in that Wells notice, which kind of, which defeats the purpose of what a Wells notice is supposed to do. It's supposed to give the defendant or the respondent enough clarity to actually submit, you know, a defense of the facts to the commission in advance of being charged. So I think that the Wells notice was vague enough that no one is necessarily certain as to what the SEC is viewing as securities in that instance. You know, they could view the security, they could view the tokens that were listed in the Wahee case as security. As security.

they've already made that claim. They could view others, but there aren't futures contracts trading on those. So those aren't within the current regulatory fold where the SEC, you know, as lack of action, you know, basically constitutes an acknowledgment of the status of a product as being within the CFTC's jurisdiction and trading as a non-security. All right. Last quick question for you both. So we've now talked about, you know, this relationship.

that the government has to crypto and then how some of that could play out in a geopolitical way. And I was wondering if you both just had any message that you wanted to give to essentially any entity or multiple entities in the government, whether regulators or lawmakers or both, what would that be? I would say that there is an opportunity to create a regulatory system that both respects the technology and its promise as well as protects consumers. There's some hard work that needs to be done. The current approach is not sustainable,

and the innovation is valuable enough and meaningful enough and is impactful enough and transformative enough that that effort's required, and it's required now. Yeah, mine's very simple. When the executive oversteps the balance of its authority, we are a system with checks and balances. And one check on their authority is the courts, of course, and that'll play out in time, but also it's Congress's duty to act as a check on some of these federal

regulators that are clearly overstepping the bounds of their authority and acting outside the normal course of duty. And I would like to see more from Congress in investigating the actions of the federal agencies that are depriving crypto firms to their bank relationships. I think it's very straightforward that it's not their job to determine who these banks can do business with if it's a legal industry, which it is. So I look forward to seeing more from Congress. All right. Perfect. Well, where can people learn more about each of you and your work? All my entire corpus can be found in Nick Carter.com. I don't have one of those, but my biography is on A16Z crypto's website. You can learn more about A16Z crypto or A16Z proper through his website.

Nick and I are both on Twitter. Perfect. It's been a pleasure having you both on Unchained. Thanks so much. Thanks so much for joining us today. To learn more about Brian, Nick, and all the regulatory actions being brought against the crypto industry, check out the show notes for this episode. Unchained is produced by me, Laura Shin, both up from Anthony Youen, Mark Murdoch, Matt Pilchard, Zach Seward, Juan Navanovich, Sam Shree Rom, Ginny Hogan, Ben Munster, Jeff Benson, Leandro Camino,

Pamma Jimdar, Shashonk, and CLK transcription. Thanks for listening. You know,